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    <title>2019 (2) TMI 2043 - ITAT MUMBAI</title>
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    <description>Interest paid by an Indian branch of a foreign bank to its overseas head office was treated as not taxable in India where the Tribunal&#039;s earlier coordinate decision in the assessee&#039;s own case had already resolved the issue in its favour and no higher authority had displaced that view. The Revenue&#039;s reliance on section 40(a)(i) also failed because that provision was not the basis of the assessment in the relevant year and was advanced on an incorrect factual premise. The Tribunal therefore dismissed the Revenue&#039;s appeal and sustained the relief granted by the first appellate authority.</description>
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      <title>2019 (2) TMI 2043 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=303944</link>
      <description>Interest paid by an Indian branch of a foreign bank to its overseas head office was treated as not taxable in India where the Tribunal&#039;s earlier coordinate decision in the assessee&#039;s own case had already resolved the issue in its favour and no higher authority had displaced that view. The Revenue&#039;s reliance on section 40(a)(i) also failed because that provision was not the basis of the assessment in the relevant year and was advanced on an incorrect factual premise. The Tribunal therefore dismissed the Revenue&#039;s appeal and sustained the relief granted by the first appellate authority.</description>
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